FSA has published a report following a review of industry practices on complying with the UK financial sanctions regime. It found some misperceptions on fundamental issues as well as some examples of good practice. Among the problems were:  

  • firms believing they were exempt from the regime for various reasons: some thought it covered only firms that hold client money, others that there was a minimum financial limit and some that it did not apply to some areas of the financial sector, particularly insurance;  
  • a belief the regime did not cover UK residents; and  
  • confusion between AML requirements (particularly for PEPs) and the sanctions regime and in some cases belief that compliance with AML requirements meant compliance with sanctions laws.  

FSA expects all firms to read its report and make appropriate changes to their systems.